AGREEMENT BETWEEN THE GOVERNMENT OF THE KYRGYZ REPUBLIC AND GOVERNMENT OF THE REPUBLIC OF KOREA

of December 11, 2012

About avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and the capital

Government of the Kyrgyz Republic and Government of the Republic of Korea,

Wishing to sign the Agreement on avoidance of double taxation and prevention of tax avoidance concerning taxes on the income and on the capital,

Agreed as follows:

Article 1. Persons to whom the Agreement is applied

This agreement is applied to persons who are residents of one or both Contracting States.

Article 2. Taxes to which the Agreement extends

This agreement is applied to the taxes on the income and the capital levied on behalf of the Contracting State, or its political or administrative divisions or regional authorities irrespective of method of their collection.

2. All taxes levied from total of income on the total amount of the capital, or from separate elements of the income or the capital, including taxes on the income from alienation of personal and real estate, taxes levied from the total amount of the salary or the salary paid by the companies and also the taxes levied from the income from capital gain are considered as taxes on the income and the capital.

3. The existing taxes to which this agreement extends are in particular:

a) in the Kyrgyz Republic:

(i) income tax and other income of legal entities;

(ii) the income tax from physical persons;

(iii) non-personal tax

(further referred to as as "taxes of the Kyrgyz side");

b) in the Republic of Korea:

(i) income tax;

(ii) income tax of corporations;

(iii) the specific tax on agricultural development;

(iv) the local tax on profit

(further referred to as as taxes of "The Korean side").

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